Last update March 2022 Privacy Policy
At E-GAP, we are committed to protecting the data we collect to provide you with our services, in accordance with the applicable rules in this area and in particular the Law n°78-17 of 6 January 1978 relating to data processing, files and freedoms, as amended (“Loi Informatique et Libertés”) as well as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 known as the General Data Protection Regulation (“RGPD”). Therefore, we have put in place a policy describing how your personal data is processed and protected. E-GAP France S.A.S. (subcontractor) collects your Personal Data on behalf of E-GAP S.r.l. (“Data Controller), in the sense of the RGPD.For any question concerning our Privacy Policy, and more generally, the collection and processing of your Personal Data by E-GAP S.r.l., do not hesitate to contact us at the following address: privacy@E-GAP.com and/or consult the website of the Commission Nationale de l’Informatique et des Libertés (“CNIL”). Table of contents:
- 1 Quelles sont les Données que nous recueillons ?. 2
- 2 Quelles sont les données que nous collectons automatiquement ?. 2
- 3 Quelle est la base légale du Traitement ?. 3
- 4 Quelles sont les finalités du Traitement ?. 3
- 5 Traitement automatisé de Données Personnelles. 3
- 6 Transfert de Données Personnelles. 3
- Qui a accès à vos Données Personnelles ?. 4
- Combien de temps conservons-nous vos Données ?. 4
- Contact 5
1. Definitions
“App” or “Application” means the E-GAP application downloadable from your phone.
“Device” means any device, phone or computer, through which you interact with Us.
“Personal Data” or “Data” means any information that you voluntarily provide to Us or that is automatically collected when you interact with Us.
“We”, “us”, “our” and “E-GAP” means the E-GAP group.
“Policy” means this Privacy Policy.
“Services” means the services provided by E-GAP via its website or app.
“Site” means the public website of E-GAP, accessible at www.e-gap.com.
“Processing” means any processing carried out in relation to your Personal Data.
“User” or “Customer” means any person over the age of sixteen who uses our Services and who has a login to access their Account.
“Visitor” means any person who visits our site.
2. Who are we?
E-GAP France S.A.S is a limited liability company registered in the Paris Trade and Companies Register under number 902 293 547 with its registered office at 75 avenue Parmentier 75544 Paris Cedex 11. E-GAP France is a subsidiary of the Italian company E-GAP S.r.l., registered under the following VAT/CF number: 14253861000 and having its registered office at Via Flavia, 3 – 00187 Rome.
E-GAP France S.A.S. (processor) collects your Personal Data on behalf of E-GAP S.r.l. (Data Controller), within the meaning of the RGPD.
3. Processing of Personal Data
This Privacy Policy applies to the Data we collect about you when you are a User or Visitor.
3.1 Which Data Do We Collect?
Accessing and using the Site and the Application implies the collection and processing of your Personal Data, namely:
- Your surname, first name, date of birth, e-mail address and telephone number;
- An identity document (national identity card, passport);
- The e-mail addresses of your friends or any other person who may be interested in our Services;
- The content of messages sent via chat and e-mail;
- The configuration log file of your Device, including WiFi credentials, if you choose to automatically synchronise them with other Devices;
- The Data necessary to make payments for the Services requested;
- Data relating to your application from the “Careers” section of our Site.
3.2 Which Data Do We Collect Automatically?
The Personal Data we automatically collect and use are:
– Your Internet Protocol (IP) address;
– Information about your Device and your connection, such as browser type and version, operating system or time zone setting;
– The location of your Device when you request our Services (geolocation);
– The phone number you use to call us, your email address and your interaction with our website content
3.3 What is the legal basis for the Processing?
In accordance with Article 6 of the GDPR, E-GAP processes your Personal Data only when there is an appropriate legal basis, namely:
- Your consent to the processing of your Personal Data;
- The performance of the contract for the provision of our Services;
- To comply with our legal obligations;
- To pursue our legitimate interests.
The Data required for the provision of our Services are designated as “mandatory” and are filled in as follows: *Required fields. It concerns your identity, your email address, your telephone number and your location. If you do not provide us with this Data or do not consent to its processing, we will not be able to provide you with the full range of our Services.
3.4 What are the purposes of the Processing?
Your Personal Data are collected and processed only for the purposes set out in this article, namely:
– Manage your requests and provide you with our Services;
– To communicate with you about our Services and any promotional offers (newsletters, emails);
– To provide certain “additional services”, including through the assistance and/or collaboration of third party providers;
– Communicate with you via chat, email or telephone and provide you with assistance when you request it;
– To manage your application as part of a recruitment process;
– To improve the quality of our Services;
– To improve your experience on our Site and App;
– Resolve any disputes or problems you may have with the use of our Services.
3.5 Automatic Processing of Personal Data
E-GAP may use certain automated processes in the processing of your Data that may lead to automated decision making or profiling in order to provide our Services to you. For example, in order to identify and implement our Services in the areas most suitable for our business, we may implement an automated process based on an algorithm and/or profiling.
3.6 Transfer of Personal Data
We primarily process your Data within the European Union. If Personal Data is transferred outside the European Union, we will ensure that it is transferred in accordance with this Policy, the applicable data protection regulations and to a country that guarantees a level of protection at least equivalent to that provided by the RGPD.
In the course of the development of the E-GAP group, we may sell or buy other companies or services. In this case, E-GAP undertakes to ensure the protection of your Personal Data and includes compliance with this Policy in the conditions for carrying out the planned operation.
Within the framework of our recruitment and according to the job offer to which you apply and the various countries where E-GAP works, your Data may be transferred to other companies of the E-GAP group, subject to compliance with this Policy.
4. Who has access to your Personal Data?
Your Data may be shared between companies of the E-GAP group or controlled by it, and of course our teams may have access to it, depending on the purpose of the Processing.
E-GAP undertakes to communicate your Personal Data only to trusted service providers, who process it on our behalf, according to our instructions, in accordance with this Privacy Policy and in compliance with any other appropriate security and confidentiality measures. Furthermore, these service providers only have access to Personal Data that is strictly necessary for the performance of their activities.
Your Data may thus be processed by technical service providers of E-GAP, as follows:
| Who? | Why? |
| CloudFlare | Network performance, traffic management and protection against cyber attacks |
| Audience profiling | |
| Hetzner | Hébergement (Europe) |
| Salesforce | CRM |
| Stripe | Payment solutions |
| Zuora | Billing of payment |
5. How long do we keep your Data?
We keep your Data for varying periods of time depending on the purposes for which we collect it.
Payment Data is retained for a maximum of 12 months from the date of collection.
Your User Account Information is retained for as long as you use our Services and for a maximum of 10 years from your last use of the Services. Beyond that, certain commercial Data may be kept longer, in particular for evidentiary purposes for a period of 5 years, in civil and commercial matters, as well as for accounting or tax purposes, i.e. 10 years from their date. In this respect, we keep the history of your transactions and payments for a period of 5 years from the end of our business relationship.
In relation to recruitment and application processing, we will retain your Data throughout the recruitment process and may retain it for up to one year after the end of the selection process for future recruitment to equivalent positions.
We may also keep your Data for longer if we are required to do so by law or in the event of a claim or dispute, to defend our interests.
6. What are your rights?
In accordance with Chapter III of the RGPD, you have the right to:
– Access and obtain a copy of your Personal Data (article 15);
– Request the update and/or rectification of your Personal Data (Article 16);
– Request the deletion of your Personal Data, i.e. benefit from the “right to be forgotten” ( Article 17), subject to the Personal Data that must be kept in application of a legal obligation, in particular the Data relating to payments and KYC;
– Obtain the limitation of the Processing of your Personal Data (Article 18);
– Obtain the Personal Data you have provided in a structured, commonly used and electronically readable format, so that you can eventually transmit it to another controller (Article 20);
– Oppose the Processing of your Personal Data (Article 21).
Insofar as the Processing of Personal Data is based on your consent, you have the right to withdraw your consent at any time, without this affecting the Processing that took place prior to the withdrawal.
With regard to prospecting and direct marketing messages, you may request that these communications be stopped at any time by unsubscribing, via the systematic link provided in these messages.
For more information on your rights or for any recourse, you can also consult the CNIL website available at the following address www.cnil.fr.
7. Update of this Privacy Policy
We endeavour to keep our Privacy Policy up to date. In the event of a substantial change, we undertake to inform you in advance on our Site or by any other means.
8. Contacts
E-GAP has appointed a person in charge of questions relating to the Processing of Personal Data who can be contacted at the following e-mail address: privacy@e-gap.com
